San Joaquin Valley Air Pollution Control District
Authority to Construct
Application Review
Soil Decontamination Operation Using Activated Carbon
Facility Name:
Mailing Address:
Date:
Engineer:
Lead Engineer:
Contact Person:
Telephone:
Application #(s):
Project #:
Deemed Complete:
I. Proposal
Facility Name is applying for an Authority to Construct (ATC) permit for a soil decontamination
operation served by an activated carbon system.
OR
Facility Name is applying for an Authority to Construct (ATC) permit to modify their soil
decontamination operation served by an activated carbon system to (state the type of
modification).
II. Applicable Rules
Rule 2201
New and Modified Stationary Source Review Rule (4/21/11)
Rule 2410
Prevention of Significant Deterioration (6/16/11)
Rule 2520
Federally Mandated Permits (6/21/01)
Rule 4101
Visible Emissions (2/17/05)
Rule 4102
Nuisance (12/17/92)
Rule 4651 Soil Decontamination Operations (9/20/07)
CH&SC 41700 California Health and Safety Code (Health Risk Assessment)
CH&SC 42301.6 California Health and Safety Code (School Notice)
Public Resources Code 21000-21177: California Environmental Quality Act (CEQA)
California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000-15387: CEQA
Guidelines
III. Project Location
Page 1
Facility Name
Facility #, Project #
The facility is located at [location]. The District has verified that the facility [is/is not] located within
1,000 feet of the outer boundary of any K-12 school. Therefore, pursuant to CH&SC 42301.6,
California Health and Safety Code (School Notice), public notification [is/is not] required.
If located at existing stationary source then state:
Although this operation is located at [Facility Name and #], it is considered a separate stationary
source with a different SIC code since the soil remediation operation is not considered a normal
business activity of the existing facility.
IV. Process Description
VOC will be extracted from subsurface soil by mechanically drawing air through the soil matrix.
This will be done by connecting a vacuum pump with blower motor to extraction wells. When
suction is applied to the wells it induces a subsurface airflow radially toward perforations in the
well casings. Organic vapors are removed by adsorption as the gas stream passes through a
bed of specially “activated” carbon. This material has a very large surface area for adsorption
due to the presence of a large number of pores throughout the carbon. The organic vapors
diffuse into these pores and are retained on the carbon surface due to both chemical and
physical forces. For this operation, [two/three] carbon canisters will be connected in series.
When the first canister approaches the saturation point where it is unable to adsorb additional
VOCs, the canister is removed from service with the second canister in series now serving as
the first and a fresh canister installed as the new final canister. In this way, if the first canister
reaches saturation before it can be replaced, extracted VOCs are still adsorbed by the second
canister rather than passing through to atmosphere. The activated carbon system will capture
at least 95% of the VOC in the process stream prior to discharge into the atmosphere.
Operating Schedule:
The operating schedule is [ ] hr/day and [ ] days/year.
V. Equipment Listing
Activated Carbon System:
Manufacturer: [
[
Model #: [
Control Efficiency: [
]
] carbon canisters @ [ ] lbs each
]
] % (Per applicant, District BACT requirement: 95%)
Extraction Blower/Motor:
Power Rating: [ ] hp
Maximum Stack Flowrate: [ ] cfm
Page 2
Facility Name
Facility #, Project #
C-xxxx-x-x:
SOIL REMEDIATION PROJECT SERVED BY [TWO] [XXX] LB [MANUFACTER],
MODEL [XXX], CARBON CANISTERS CONNECTED IN SERIES
VI. Emission Control Technology Evaluation
Activated Carbon System:
Carbon adsorption is a remediation technology in which pollutants are removed from air by
physical adsorption onto activated carbon grains. Carbon is "activated" for this purpose by
processing the carbon to create porous particles with a large internal surface area that attracts
and adsorbs organic molecules as well as certain metal and inorganic molecules.
The control equipment consists of a carbon system, as described in Section IV above. The VOCcontaminated air from the extraction wells will be ducted through the carbon system where a
minimum of 95% (by weight) of the VOC will be captured. After treatment by the carbon system
the treated effluent stream is released to the atmosphere. To prevent potential VOC emissions
from the spent carbon canisters, the canisters will be sealed gas-tight and sent to a regeneration
facility or landfill for disposal.
VII. Emissions Calculations
A. Assumptions
Process Weight:





Maximum influent concentration: [ ] ppmv as gasoline of VOC being removed from the
soil (proposed by applicant)
Maximum influent rate: [ ] scfm
Control efficiency: [ ]% (as proposed by the applicant) minimum BACT requirement
Molecular weight of gasoline = 100 lb/lb-mole (EPA On-line Tools for Site Assessment
Calculation)
Molecular weight of methane = 16.043 lb/lb-mole
B. Emission Factors
(Include the following conversion if ppmv provided is not in ppmv as methane)
VOC concentrations are measured with reference to methane. This requires that the
molecular weight be adjusted to methane. Since the applicant stated that the maximum
influent concentration is [ ] ppmv as [gasoline @ 100 lb/lb-mole], the adjusted concentration
can be determined as follows:
(mass emissions)as methane = mass emissionsas gasoline
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Facility Name
Facility #, Project #
(concentration x flowrate x molar volume x molecular weight)methane = (concentration x
flowrate x molar volume x molecular weight)gasoline
(concentration x molecular weight)methane = (concentration x molecular weight)gasoline
C. Calculations
1. Pre-Project Potential to Emit (PE1)
Since this is a new emissions unit, the PE1 = 0
OR
The daily, annual, and quarterly pre-project emissions are shown below:
Pre-Project Potential to Emit (PE1)
NOx
SOx
PM10
CO
VOC
Daily PE
----[ ]
Annual PE
----[ ]
Quarterly PE
----[ ]
2. Post Project Potential to Emit PE (PE2)
Influent concentrationmethane
= concentrationgasoline x molecular weightgasoline / molecular weightmethane
= [ ] ppmv-gasoline x 100 lb-gasoline/lb-mole / 16.043 lb-methane/lb-mole
= [ ] ppmv as methane
Maximum effluent VOC concentrationmethane
= influent concentrationmethane x (1 – control efficiency)
= [ ] ppmv as methane x (1 – 0.95)
= [ ] ppmv as methane
PE VOCcontrolled = Influent concentration as methane (ppmv)  Influent Flow Rate
(ft3/min)  1 lb-mole/379.5 ft3  Mol. Wt. (lb/lb-mole)  1440 min/day
x (1 - control efficiency)
= ([ ]  10-6)  ([ ] ft3/min)  (1 lb-mole/379.5 ft3)  (16.043 lb/lb-mole)
 1440 min/day
Page 4
Facility Name
Facility #, Project #
= [ ] lb-VOC/day
(If the daily controlled PE above is below 2 pounds per day, add the following section)
Once effluent VOC emissions drop below 2 pounds per day, the emissions unit is no
longer subject to BACT and may operate at a lower control efficiency or without any
controls at all. However, since the VOC emissions calculated above are below 2.0 lbVOC/day, the calculated VOC emission will be adjusted to 2.0 lb-VOC/day in order to
show no increase in emissions from this operation once the control device is reduced or
taken off-line. The effluent concentration will be recalculated as follows:
Concentration (ppmv) =
(2.0 lbs/day)  [Influent Flow Rate (ft3/min)  1 lb-mole/379.5
ft3  Mol. Wt. (lb/lb-mole)  1440 min/day x 10-6]
=
(2.0 lbs/day)  [([ ] ft3/min)  (1 lb-mole/379.5 ft3)  ([ ] lb/lbmole)  1440 min/day  10-6]
=
[ ] ppmv
Verification of Carbon Breakthrough:
Per District policy of carbon breakthrough in a carbon adsorption remediation project, the first
or first set of canisters must be capable of operating at least 168 consecutive hours (or seven
days) at the maximum influent concentration before breakthrough. The last canister is only for
backup upon breakthrough of the first set of canisters. Therefore, the breakthrough period for
the first set is required to be no less than seven days, calculated as follows:
Max influent Contaminant rate = [ X ] lb/day
Max effluent Contaminant rate = [ Y ] lb/day (based on a [95]% control)
VOC adsorbed = Max Influent VOC – Max Effluent VOC
[ X ] – [Y] lb/day
= [ Z ] lb/day
# of canisters proposed = [ # ]
Mass of carbon/canister = [ M ] lbs (proposed by the applicant)
Mass of Breakthrough Carbon* = (number of canisters - 1) x (M)
= [ A ] lbs
*The last canister is not included as it is only used for backup.
Assuming a working bed capacity of 20% for carbon (weight of solvent per weight of carbon)
before breakthrough, the total mass of carbon from the canisters to adsorb solvent is:
[ A ] lbs  (0.2) = [ B ] lbs
The number of days before breakthrough would then be:
Page 5
Facility Name
Facility #, Project #
[ B ] lb  [ Z ] lb/day = [ # ] days
Since the breakthrough period is greater than seven days, this project is approvable.
Post-Project Potential to Emit (PE2)
Pollutant (lb/day)
(lb/yr)
NOx
--SOx
--PM10
--CO
--VOC
[ ]
[ ]
Note: PEannual (lb/yr) = PE (lb/day) x 365 (days/yr)
3. Pre-Project Stationary Source Potential to Emit (SSPE1)
[For New Facilities]
Since this is a new facility, SSPE1 is equal to zero.
[For existing facilities]
Pursuant to Section 4.9 of District Rule 2201, the Pre-project Stationary Source
Potential to Emit (SSPE1) is the Potential to Emit (PE) from all units with valid
Authorities to Construct (ATC) or Permits to Operate (PTO) at the Stationary Source
and the quantity of emission reduction credits (ERC) which have been banked since
September 19, 1991 for Actual Emissions Reductions that have occurred at the source,
and which have not been used on-site.
Since this is an existing facility, SSPE1 is equal to the PETotal Pre-Project for all criteria
pollutants.
The Pre-project Stationary Source Potential to Emit (SSPE1) is presented in the following
table:
Pre-Project Stationary Source Potential to Emit [SSPE1] (lb/year)
Permit #
C-xxxx-x-x
Total
NOX
0
0
SOx
0
0
PM10
0
0
CO
0
0
4. Post-Project Stationary Source Potential to Emit (SSPE2)
Page 6
VOC
0
0
Facility Name
Facility #, Project #
Pursuant to Section 4.10 of District Rule 2201, the Post-project Stationary Source
Potential to Emit (SSPE1) is the Potential to Emit (PE) from all units with valid
Authorities to Construct (ATC) or Permits to Operate (PTO) at the Stationary Source
and the quantity of emission reduction credits (ERC) which have been banked since
September 19, 1991 for Actual Emissions Reductions that have occurred at the source,
and which have not been used on-site. The Post-project Stationary Source Potential to
Emit (SSPE2) is presented in the following table:
Post Project Stationary Source Potential to Emit [SSPE2] (lb/year)
Permit #
C-xxxx-x-x
Total
NOX
0
0
SOx
0
0
PM10
0
0
CO
0
0
VOC
0
0
5. Major Source Determination
Rule 2201 Major Source Determination:
Pursuant to Section 3.24 of District Rule 2201, a Major Source is a stationary source
with post-project emissions or a Post Project Stationary Source Potential to Emit
(SSPE2), equal to or exceeding one or more of the following threshold values.
However, Section 3.24.2 states, “for the purposes of determining major source status,
the SSPE2 shall not include the quantity of emission reduction credits (ERC) which
have been banked since September 19, 1991 for Actual Emissions Reductions that
have occurred at the source, and which have not been used on-site.”
Major Source Determination (lb/year)
Pollutant
NOx
SOx
PM10
CO
SSPE2 (lb/yr)
[ ]
[ ]
[ ]
[ ]
Major Source Threshold
20,000 140,000 140,000 200,000
[Yes or
[Yes or
[Yes or
[Yes or
Major Source?
No]
No]
No]
No]
VOC
[ ]
20,000
[Yes or
No]
Since none of the threshold values in the above table are exceeded, this facility is not a
Major Source.
Or
Since the annual VOC emissions are above the major source threshold values in the
above table, this facility is now a Major Source for VOC. (If this is true, this project is
NO LONGER A GEAR. Check with your supervisor before further processing.)
Rule 2410 Major Source Determination:
Page 7
Facility Name
Facility #, Project #
The facility or the equipment evaluated under this project is not listed as one of the
categories specified in 40 CFR 52.21 (b)(1)(i). Therefore the following PSD Major
Source thresholds are applicable.
PSD Major Source Determination
(tons/year)
Estimated Facility PE before
Project Increase
PSD Major Source Thresholds
PSD Major Source ? (Y/N)
NO2
VOC
SO2
CO
PM
PM10
CO2e
0
0
0
0
0
0
0
250
250
250
250
250
250
100,000
N
N
N
N
N
N
N
As shown above, the facility is not an existing major source for PSD for at least one
pollutant. Therefore the facility is not an existing major source for PSD.
6. Baseline Emissions (BE)
a) Annual BE
BE = Pre-project Potential to Emit for:




Any unit located at a non-Major Source,
Any Highly-Utilized Emissions Unit, located at a Major Source,
Any Fully-Offset Emissions Unit, located at a Major Source, or
Any Clean Emissions Unit, located at a Major Source.
otherwise,
BE = Historic Actual Emissions (HAE), calculated pursuant to Section 3.22
Since this is a new facility, the annual BE is equal to zero.
OR
Since this unit is not located at a major source, BE = Pre-project Potential to Emit.
Permit Number
C-xxxx-xx
Annual BE (lb/year)
NOx
SOx
PM10
0
0
0
Page 8
CO
0
VOC
[ ]
Facility Name
Facility #, Project #
7. SB 288 Major Modification
SB 288 Major Modification is defined in 40 CFR Part 51.165 as "any physical change in
or change in the method of operation of a major stationary source that would result in a
significant net emissions increase of any pollutant subject to regulation under the Act."
As discussed in Section VII.C.5 above, this facility is not a major source for any of
the pollutants addressed in this project; therefore, the project does not constitute a
SB 288 Major Modification
8. Federal Major Modification
District Rule 2201, Section 3.18 states that Federal Major Modifications are the same as
“Major Modification” as defined in 40 CFR 51.165 and part D of Title I of the CAA.
Since this facility is not a Major Source for any pollutants, this project does not
constitute a Federal Major Modification. Additionally, since the facility is not a major
source for PM10 (140,000 lb/year), it is not a major source for PM2.5 (200,000 lb/year).
9. Rule 2410 – Prevention of Significant Deterioration (PSD) Applicability
Determination
Rule 2410 applies to pollutants for which the District is in attainment or for unclasssified,
pollutants. The pollutants addressed in the PSD applicability determination are listed as
follows:






NO2 (as a primary pollutant)
SO2 (as a primary pollutant)
CO
PM
PM10
Greenhouse gases (GHG): CO2, N2O, CH4, HFCs, PFCs, and SF6
The first step of this PSD evaluation consists of determining whether the facility is an
existing PSD Major Source or not (See Section Vll.C.5 of this document).
In the case the facility is an existing PSD Major Source, the second step of the PSD
evaluation is to determine if the project results in a PSD significant increase.
In the case the facility is NOT an existing PSD Major Source but is an existing source,
the second step of the PSD evaluation is to determine if the project, by itself, would be a
PSD major source.
In the case the facility is new source, the second step of the PSD evaluation is to
determine if this new facility will become a new PSD major Source as a result of the
project and if so, to determine which pollutant will result in a PSD significant increase.
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Facility Name
Facility #, Project #
A. Potential to Emit for New or Modified Emission Units vs PSD Major Source
Thresholds
As a screening tool, the project potential to emit from all new and modified units is
compared to the PSD major source threshold, and if total project potential to emit
from all new and modified units is below this threshold, no futher analysis will be
needed.
The facility or the equipment evaluated under this project is not listed as one of the
categories specified in 40 CFR 52.21 (b)(1)(i). Therefore the following PSD Major
Source thresholds are applicable.
(Enter VOC emissions)
PSD Major Source Determination: Potential to Emit
(tons/year)
NO2
VOC
SO2
CO
PM
PM10
CO2e
Total PE from New and Modified
0
Units
0
0
0
0
0
0
PSD Major Source threshold
250
250
250
250
250
250
100,000
New PSD Major Source?
N
N
N
N
N
N
N
As shown in the table above, the project potential to emit, by itself, does not exceed
any of the PSD major source thresholds. Therefore, Rule 2410 is not applicable and
no further discussion is required.
10. Quarterly Net Emissions Change (QNEC)
The QNEC is calculated solely to establish emissions that are used to complete the
District’s PAS emissions profile screen. Detailed QNEC calculations are included in
Appendix B.
VIII. Compliance
Rule 2201 - New and Modified Stationary Source Review Rule
A. BACT
1. BACT Applicability
BACT requirements are triggered on a pollutant-by-pollutant basis and on an emissions
unit-by-emissions unit basis for the following*:
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Facility Name
Facility #, Project #
a. Any new emissions unit with a potential to emit exceeding two pounds per day,
b. The relocation from one Stationary Source to another of an existing emissions unit
with a potential to emit exceeding two pounds per day,
c. Modifications to an existing emissions unit with a valid Permit to Operate resulting in an
AIPE exceeding two pounds per day, and/or
d. Any new or modified emissions unit, in a stationary source project, which results in a
Major Modification.
*Except for CO emissions from a new or modified emissions unit at a Stationary Source with an SSPE2 of
less than 200,000 pounds per year of CO.
The applicant is proposing to install a new emissions unit with a PE of [ ] lb/day for VOC as
calculated in section VII.C.2. Since the daily VOC emissions are [greater/not greater] than
2.0 lbs/day, BACT [will or will not] be triggered.
OR
The applicant is proposing to modify its existing emissions unit with an AIPE of [ ] lb/day
for VOC as calculated in the following section. Since the daily VOC emissions are
[greater/less] than 2.0 lbs/day, BACT [will/will not] be triggered.
Adjusted Increase in Permitted Emissions (AIPE)
AIPE = PE2 – HAPE where,
AIPE =
PE2 =
HAPE =
Adjusted Increase in Permitted Emissions, lb/day.
the emission unit’s post project Potential to Emit, lb/day.
the emission unit’s Historically Adjusted Potential to
Emit, lb/day.
Historically Adjusted Potential to Emit (HAPE) Calculations:
HAPE = PE1 x (EF2 / EF1) where,
PE1 = The emission unit’s Potential to Emit prior to modification or relocation.
EF2 = The emission unit’s permitted emission factor for the pollutant after modification
or relocation. If EF2 is greater than EF1 then EF2/EF1 shall be set to 1.
EF1 = The emission unit’s permitted emission factor for the pollutant before the
modification or relocation.
EF1 = [ ] % (Taken from project # [ ])
EF2 = [ ] % (As proposed by the applicant, 95% District BACT requirement)
AIPE (lb/day) = PE2 (lb/day) – [PE1 (lb/day) x (EF2 / EF1)]
= PE2 (lb/day) – [PE1 (lb/day) x (0.95 / 0.95)]
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Facility Name
Facility #, Project #
= PE2 (lb/day) – [PE1 (lb/day) x 1]
= PE2 (lb/day) – PE1 (lb/day)
Adjusted Increase in Permitted Emissions (AIPE)
Pollutant
NOx
SOx
PM10
CO
VOC
PE2
Daily Post Project
(lb/day)
----[ ]
PE1
Daily Pre Project
(lb/day)
----[ ]
AIPE
(lb/day)
----[ ]
2. BACT Guidance
Per District Policy APR 1305, Section IX, “A top-down BACT analysis shall be performed
as a part of the Application Review for each application subject to the BACT requirements
pursuant to the District’s NSR Rule for source categories or classes covered in the BACT
Clearinghouse, relevant information under each of the following steps may be simply cited
from the Clearinghouse without further analysis."
SJVUAPCD BACT Clearinghouse Guideline 2.1.3 specifies the achieved in practice or
contained in SIP BACT and technologically feasible BACT for soil remediation operations
utilizing a carbon adsorption system. Therefore, relevant information will be cited without
further analysis.
See Appendix A: BACT Clearinghouse Guideline 2.1.3
3. Top-Down BACT Analysis
The applicant is proposing to use a carbon adsorption system with 95% or greater control
efficiency. Per the Top-Down analysis in Appendix I of this evaluation, this proposed
equipment is the achieved in practice BACT and there is not a more effective
technologically feasible control. Therefore, the proposed equipment satisfies the BACT
requirement.
B. Offsets
1. Offset Applicability
Pursuant to Section 4.5.3, offset requirements shall be triggered on a pollutant by
pollutant basis and shall be required if the Post Project Stationary Source Potential to
Emit (SSPE2) equals to or exceeds the offset threshold levels in Table 4-1 of Rule 2201.
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Facility Name
Facility #, Project #
The following table compares the post-project facility-wide annual emissions in order to
determine if offsets will be required for this project.
Offset Determination (lb/year)
NOX
SOX
PM10
Post Project SSPE
(SSPE2)
Offset Threshold
Offsets triggered?
CO
VOC
--
--
--
--
--
20,000
No
54,750
No
29,200
No
200,000
No
20,000
No
2. Quantity of Offsets Required
As shown in the table above, the SSPE2 is not greater than or equal to the offset
threshold levels for any criteria pollutant. Therefore, offsets will not be required.
OR
As shown in the table above, the SSPE2 meets or exceeds the offset threshold levels.
Therefore, offsets will be required. (If this is true, this project is NO LONGER A GEAR.
Check with your supervisor before further processing.)
C. Public Notification
1. Applicability
Public noticing is required for:
a.
b.
c.
d.
e.
Any new Major Source, which is a new facility that is also a Major Source,
SB 288 Major Modifications or Federal Major Modifications,
Any new emissions unit with a Potential to Emit greater than 100 pounds during
any one day for any one pollutant,
Any project which results in the offset thresholds being surpassed, and/or
Any project with an SSIPE of greater than 20,000 lb/year for any pollutant.
a) New Major Source
Example (a): (For a new facility – non Major Source.)
New Major Sources are new facilities, which are also Major Sources. As shown in
Section VII.C.5 above, the SSPE2 is not greater than the Major Source threshold for
any criteria pollutant. Therefore, public noticing is not required for this project for
new Major Source purposes.
Example (c): (For an existing facility.)
New Major Sources are new facilities, which are also Major Sources. Since this is
not a new facility, public noticing is not required for this project for New Major Source
purposes.
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Facility Name
Facility #, Project #
b) SB 288 or Federal Major Modification
As demonstrated in VII.C.7, this project does not constitute a Major Modification;
therefore, public noticing for Major Modification purposes is not required.
c) PE > 100 lb/day
Example (a): (For a project not including a new emissions unit.)
Applications which include a new emissions unit with a Potential to Emit greater than
100 pounds during any one day for any pollutant will trigger public noticing
requirements. There are no new emissions units associated with this project;
therefore public noticing is not required for this project for Potential to Emit
Purposes.
Example (b): (For a project including a new emissions unit – PE  100 lb/day.)
Applications which include a new emissions unit with a Potential to Emit greater than
100 pounds during any one day for any pollutant will trigger public noticing
requirements. As seen in Section VII.C.2 above, this project does not include a new
emissions unit which has daily emissions greater than 100 lb/day for any pollutant,
therefore public noticing for PE > 100 lb/day purposes is not required.
Example (c): (For a project including a new emissions unit – PE > 100 lb/day.)
The PE2 for this new unit is compared to the daily PE Public Notice thresholds in the
following table:
Pollutant
NOX
SOX
PM10
CO
VOC
PE > 100 lb/day Public Notice Thresholds
PE2
Public Notice
Public Notice
(lb/day)
Threshold
Triggered?
0
100 lb/day
No
0
100 lb/day
No
0
100 lb/day
No
0
100 lb/day
No
110
100 lb/day
Yes
Therefore, public noticing for PE > 100 lb/day purposes is required.
d) Offset Threshold
Example (a): (For a project not surpassing the offset threshold.)
The following table compares the SSPE1 with the SSPE2 in order to determine if
any offset thresholds have been surpassed with this project.
Page 14
Facility Name
Facility #, Project #
Pollutant
NOX
SOX
PM10
CO
VOC
SSPE1
(lb/year)
0
0
0
0
0
Offset Threshold
SSPE2
Offset
(lb/year)
Threshold
0
20,000 lb/year
0
54,750 lb/year
0
29,200 lb/year
0
200,000 lb/year
8,500
20,000 lb/year
Public Notice
Required?
No
No
No
No
No
As detailed above, there were no thresholds surpassed with this project; therefore
public noticing is not required for offset purposes.
Example (b): (For a project surpassing the offset threshold.)
The following table compares the SSPE1 with the SSPE2 in order to determine if
any offset thresholds have been surpassed with this project.
Pollutant
NOX
SOX
PM10
CO
VOC
SSPE1
(lb/year)
0
0
0
0
0
Offset Threshold
SSPE2
Offset
(lb/year)
Threshold
`0
20,000 lb/year
0
54,750 lb/year
0
29,200 lb/year
0
200,000 lb/year
22,000
20,000 lb/year
Public Notice
Required?
No
No
No
No
Yes
As detailed above, offset thresholds were surpassed for VOC with this project;
therefore public noticing is required for offset purposes. (If this is true, this project is
NO LONGER A GEAR. Check with your supervisor before further processing.)
(Note: Public notification is independent of whether or not Offsets are required. For
example, if this project involves the installation of emergency (offset-exempt)
equipment and the offset threshold is surpassed, then public notification would still
be triggered. And conversely, if this project involves the installation of new
equipment which required offsets; however, the SSPE1 was already greater than the
offset threshold, public notification would not be triggered.)
e) SSIPE > 20,000 lb/year
An SSIPE exceeding 20,000 pounds per year for any one pollutant triggers public
notice.
Public notification is required for any permitting action that results in a Stationary
Source Increase in Permitted Emissions (SSIPE) of more than 20,000 lb/year of any
affected pollutant. According to District policy, the SSIPE is calculated as the Post
Page 15
Facility Name
Facility #, Project #
Project Stationary Source Potential to Emit (SSPE2) minus the Pre-Project
Stationary Source Potential to Emit (SSPE1), i.e. SSIPE = SSPE2 – SSPE1. The
values for SSPE2 and SSPE1 are calculated according to Rule 2201, Sections 4.9 and
4.10, respectively. The SSIPE is compared to the SSIPE Public Notice thresholds in
the following table:
Example (a): (For a project where the SSIPE  20,000 lb/year.)
Stationary Source Increase in Permitted Emissions [SSIPE] – Public Notice
SSPE2
SSPE1
SSIPE
SSIPE Public
Public Notice
Pollutant
(lb/year) (lb/year)
(lb/year)
Notice Threshold
Required?
NOx
0
0
0
20,000 lb/year
No
SOx
0
0
0
20,000 lb/year
No
PM10
0
0
0
20,000 lb/year
No
CO
0
0
0
20,000 lb/year
No
VOC
8,500
0
8,500
20,000 lb/year
No
As demonstrated above, the SSIPEs for all pollutants were less than 20,000 lb/year;
therefore public noticing for SSIPE purposes is not required.
Example (b): (For a project where the SSIPE > 20,000 lb/year.)
Stationary Source Increase in Permitted Emissions [SSIPE] – Public Notice
SSPE2
SSPE1
SSIPE
SSIPE Public
Public Notice
Pollutant
(lb/year) (lb/year)
(lb/year)
Notice Threshold
Required?
NOx
0
0
0
20,000 lb/year
No
SOx
0
0
0
20,000 lb/year
No
PM10
0
0
0
20,000 lb/year
No
CO
0
0
0
20,000 lb/year
No
VOC
22,000
0
22,000
20,000 lb/year
Yes
As demonstrated above, the SSIPEs for VOC was greater than 20,000 lb/year;
therefore public noticing for SSIPE purposes is required.
f) Public Notice Action
Example (a):
(For a project not requiring public notification.)
As discussed above, this project will not result in emissions, for any criteria pollutant,
which would subject the project to any of the noticing requirements listed above.
Therefore, public notice will not be required for this project.
Example (b):
(For a project requiring public notification – PE > 100 lb/day.)
As discussed above, public noticing is required for this project for NOX emissions in
excess of 100 lb/day. Therefore, public notice documents will be submitted to the
California Air Resources Board (CARB) and a public notice will be published in a
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Facility Name
Facility #, Project #
local newspaper of general circulation prior to the issuance of the ATC for this
equipment.
(Note: When public notification is required an additional section in the EE gets
added, Section VIII-Rule 2201-F, see below)
D. Daily Emissions Limits (DEL)
Daily Emissions Limitations (DELs) and other enforceable conditions are required by
Section 3.15 to restrict a unit’s maximum daily emissions, to a level at or below the
emissions associated with the maximum design capacity. Per Sections 3.15.1 and 3.15.2,
the DEL must be contained in the latest ATC and contained in or enforced by the latest
PTO and enforceable, in a practicable manner, on a daily basis. DELs are also required to
enforce the applicability of BACT.

{1463 modified} The total controlled VOC emissions from the soil remediation system
shall not exceed XX pounds in any one day. [District Rule 2201]

The effluent VOC concentration level after the control device shall not exceed xxx
ppmv, as methane. [District Rule 2201]
E. Compliance Assurance
The following measures shall be taken to ensure continued compliance with District Rules:
1. Source Testing
VOC source testing upon initial startup is required.

{1417} Initial compliance with VOC emission rate and control efficiency requirements
shall be demonstrated by the results of the laboratory sample analysis. The results
shall be submitted to the District within 60 days of the test. [District Rule 1081]

{1414} Laboratory samples shall be taken at the initial inspection, under the
supervision of the APCD Inspector. Samples shall be taken from both the influent and
the effluent gas stream sampling ports. [District Rule 1081]

{1416} Measurements to determine the influent and the effluent gas flow rates shall
be taken at the initial inspection. Flow rate calculations shall be submitted to the
District along with the laboratory sample analysis results. [District Rule 1081]
2. Monitoring
Monitoring of influent and exhaust VOC concentrations will be required weekly. If the
uncontrolled VOC emission rate is below 2.0 lb/day as demonstrated by five consecutive
weekly samples, the control device may be taken off-line and sampling shall be performed
Page 17
Facility Name
Facility #, Project #
monthly for ongoing demonstration to show that the uncontrolled VOC emissions are
below 2.0 lb/day.

Ongoing compliance with VOC emission rate and control efficiency requirements shall
be demonstrated at least once per week by sampling both the influent and the effluent
gas streams with an FID, PID, or other District-approved VOC detection device.
[District Rule 1081]

Control device may be taken off-line after uncontrolled VOC emissions from the soil
remediation operation do not exceed 2.0 lb/day, as demonstrated by five consecutive
weekly samples using a FID, PID, or other District-approved VOC detection device.
Once taken off-line, permittee shall conduct monthly sampling with a FID, PID, or other
District-approved VOC detection device to ensure uncontrolled VOC emissions do not
exceed 2.0 lb/day. If uncontrolled VOC emissions exceed 2.0 lb/day, the control
device shall be placed back on-line as soon as possible. [District Rule 2201]
3. Record Keeping
The permittee shall maintain records for all monitored data for a period of five years.

{2780} All records shall be retained for a minimum of five years, and shall be made
available for District inspection upon request. [District Rule 2201]
4. Reporting
The permittee shall submit initial startup test report and maintain all other monitoring
records on site. Such records shall be made available for District inspection upon request.

{1417} Initial compliance with VOC emission rate and control efficiency requirements
shall be demonstrated by the results of the laboratory sample analysis. The results
shall be submitted to the District within 60 days of the test. [District Rule 1081]

{1416} Measurements to determine the influent and the effluent gas flow rates shall be
taken at the initial inspection. Flow rate calculations shall be submitted to the District
along with the laboratory sample analysis results. [District Rule 1081]

{2780} All records shall be retained for a minimum of five years, and shall be made
available for District inspection upon request. [District Rule 2201]
F. Ambient Air Quality Analysis
(Note: Applicable only when public notice is triggered, otherwise delete this section.)
An AAQA is conducted by the Technical Services group, for any project which has an
increase in emissions and triggers public notification requirements. Discuss the AAQA
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Facility Name
Facility #, Project #
results as follows. To perform an AAQA, Technical Services needs the distance from the
emissions point source (stack) to the fence line property boundaries in all four directions.
For example:
Section 4.14.1 of this Rule requires that an ambient air quality analysis (AAQA) be
conducted for the purpose of determining whether a new or modified Stationary Source will
cause or make worse a violation of an air quality standard. The Technical Services
Division of the SJVAPCD conducted the required analysis. Refer to Appendix X of this
document for the AAQA summary sheet.
The proposed location is in an attainment area for NOX, CO, and SOX. As shown by the
AAQA summary sheet the proposed equipment will not cause a violation of an air quality
standard for NOX, CO, or SOX.
The proposed location is in a non-attainment area for PM10. The increase in the ambient
PM10 concentration due to the proposed equipment is shown on the table titled Calculated
Contribution. The levels of significance, from 40 CFR Part 51.165 (b)(2), are shown on the
table titled Significance Levels.
Pollutant
PM10
Pollutant
PM10
Significance Levels
Significance Levels (g/m3) - 40 CFR Part 51.165 (b)(2)
Annual Avg.
24 hr Avg.
8 hr Avg.
3 hr Avg.
1 hr Avg.
1.0
5
N/A
N/A
N/A
Annual Avg.
0.XX
Calculated Contribution
Calculated Contributions (g/m3)
24 hr Avg.
8 hr Avg.
3 hr Avg.
X.XX
N/A
N/A
1 hr Avg.
N/A
As shown, the calculated contribution of PM10 will not exceed the EPA significance level.
This project is not expected to cause or make worse a violation of an air quality standard.
(Note: Special permit conditions may be required as a result of the AAQA.)
Rule 2410
Prevention of Significant Deterioration
As shown in Section C.9.A above, this is a new facility and the project potential to emit, by
itself, does not exceed any of the PSD major source thresholds. Therefore, this facility is not a
PSD source and Rule 2410 does not apply.
Rule 2520
Federally Mandated Operating Permits
Since this facility’s potential emissions do not exceed any major source thresholds of Rule
2201, this facility is not a major source, and Rule 2520 does not apply.
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Facility Name
Facility #, Project #
Rule 4101
Visible Emissions
Rule 4101 states that no air contaminant shall be discharged into the atmosphere for a period or
periods aggregating more than three minutes in any one hour which is as dark as, or darker than,
Ringelmann 1 or 20% opacity.
As long as the equipment is properly maintained and operated, compliance with visible
emissions limits is expected under normal operating conditions.
Rule 4102 Public Nuisance
Section 4.0 prohibits discharge of air contaminants which could cause injury, detriment,
nuisance or annoyance to the public. Public nuisance conditions are not expected as a result
of these operations, provided the equipment is well maintained. Therefore, compliance with
this rule is expected.
California Health & Safety Code 41700
(Health Risk Assessment)
Discuss whether a Health Risk Assessment is required and/or the results of the HRA,
including any special conditions to consider when issuing the ATC(s).
District Policy APR 1905 – Risk Management Policy for Permitting New and Modified
Sources specifies that for an increase in emissions associated with a proposed new
source or modification, the District perform an analysis to determine the possible impact
to the nearest resident or worksite.
Example (a): (For a project with no increase in emissions.)
As demonstrated above, there are no increases in emissions associated with this project,
therefore a health risk assessment is not necessary and no further risk analysis is
required.
(Note 1: An HRA is necessary if there is a change in any HRA parameter, i.e. exhaust
flow rate changes, stack changes, fuel use and type changes, receptor distances, etc.)
(Note 2: If example (a) is used, delete the following sections, since they don’t apply if an
HRA was not performed.)
Example (b): (For a project with a Prioritization score  1.)
An HRA is not required for a project with a total facility prioritization score of less than or
equal to one. According to the Technical Services Memo for this project (Appendix X),
the total facility prioritization score including this project was less than or equal to one.
Therefore, no future analysis is required to determine the impact from this project and
compliance with the District’s Risk Management Policy is expected.
Example (c): (For a project with a Prioritization score > 1.)
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Facility Name
Facility #, Project #
An HRA is not required for a project with a total facility prioritization score of less than
one. According to the Technical Services Memo for this project (Appendix X), the total
facility prioritization score including this project was greater than one. Therefore, a
health risk assessment was required to determine the short-term acute and long-term
chronic exposure from this project.
The cancer risk for this project is shown below:
Unit
X-XXXX-X-X
HRA Summary
Cancer Risk
XX per million
T-BACT Required
Yes/No
Discussion of T-BACT
Discuss whether a T-BACT is or is not triggered and the requirements which
satisfy T-BACT (if any).
Example (a): (For a project where T-BACT not triggered.)
BACT for toxic emission control (T-BACT) is required if the cancer risk exceeds
one in one million. As demonstrated above, T-BACT is not required for this
project because the HRA indicates that the risk is not above the District’s
thresholds for triggering T-BACT requirements; therefore, compliance with the
District’s Risk Management Policy is expected.
Example (b): (For a project where T-BACT is triggered)
BACT for toxic emission control (T-BACT) is required if the cancer risk exceeds
one in one million. As demonstrated above, T-BACT is required for this project
because the HRA indicates that the risk is above the District’s thresholds for
triggering T-BACT requirements.
For this project T-BACT is triggered for VOC. T-BACT is satisfied with BACT for
VOC (see Appendix X), which is the use of a carbon adsorption system with a
95% or greater control efficiency; therefore, compliance with the District’s Risk
Management Policy is expected.
(Note: List all conditions necessary to ensure that the equipment is operated in
the manner assumed when the RMR was performed.
See Appendix Il: Health Risk Assessment Summary
Rule 4651
Soil Decontamination Operations
The applicant is not proposing to excavate, transport, handle, ex-situ decontaminate, or
dispose contaminated soil. Therefore, per section 2.0, this rule is not applicable.
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Facility Name
Facility #, Project #
California Health & Safety Code 42301.6
(School Notice)
Reference project location and its proximity to a school and state whether or not school notice
is required for this project.
Example (a): (For a Non-School Notice project - > 1,000 feet.)
The District has verified that this site is not located within 1,000 feet of a school. Therefore,
pursuant to California Health and Safety Code 42301.6, a school notice is not required.
Example (b): (For a Non-School Notice project – no increase in emissions)
The District has verified that this site is located within 1,000 feet of a school. However,
pursuant to California Health and Safety Code 42301.6, since this project will not result in an
increase in emissions, a school notice is not required.
Example (c): (For a School Notice project.)
The District has verified that this site is located within 1,000 feet of the following school:
School Name:
Address:
[Name]
[Address]
Therefore, pursuant to California Health and Safety Code 42301.6, a school notice is required.
Prior to the issuance of the ATC for this equipment, notices will be provided to the
parents/guardians of all students of the affected school, and will be sent to all residents within
1,000 ft. of the site.
[If there is no school w/in ¼ mile of the emissions increase, include the following discussion,
otherwise delete]:
The District has verified that there are no additional schools within ¼ mile of the emission
source.
[If there is a school w/in ¼ mile of the emissions increase, include the following discussion,
otherwise delete]:
Since a school notice has been triggered (due to the above-listed school within 1,000 of the
emission source), notices will also be provided to the parents/guardians of all students from all
school sites within ¼ mile of the emission source. The following schools(s) are within ¼ mile
of the emission source:
School Name:
[Name]
Address:
[Address]
(add additional schools if necessary)
(Note: Refer to FYI - 71 for guidance on how to process a School Notice project.)
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Facility Name
Facility #, Project #
California Environmental Quality Act (CEQA)
The California Environmental Quality Act (CEQA) requires each public agency to adopt
objectives, criteria, and specific procedures consistent with CEQA Statutes and the CEQA
Guidelines for administering its responsibilities under CEQA, including the orderly evaluation of
projects and preparation of environmental documents. The San Joaquin Valley Unified Air
Pollution Control District (District) adopted its Environmental Review Guidelines (ERG) in
2001.
The basic purposes of CEQA are to:




Inform governmental decision-makers and the public about the potential, significant
environmental effects of proposed activities.
Identify the ways that environmental damage can be avoided or significantly reduced.
Prevent significant, avoidable damage to the environment by requiring changes in
projects through the use of alternatives or mitigation measures when the governmental
agency finds the changes to be feasible.
Disclose to the public the reasons why a governmental agency approved the project in
the manner the agency chose if significant environmental effects are involved.
Consistent with California Environmental Quality Act (CEQA) and CEQA Guidelines
requirements, the San Joaquin Valley Air Pollution Control District (District) has adopted
procedures and guidelines for implementing CEQA. The District’s Environmental Review
Guidelines (ERG) establishes procedures for avoiding unnecessary delay during the District’s
permitting process while ensuring that significant environmental impacts are thoroughly and
consistently addressed. The ERG includes policies and procedures to be followed when
processing permits for projects that are exempt under CEQA.
The State Legislature granted a number of exemptions from CEQA, including projects that
require only ministerial approval. Based upon analysis of its own laws and consideration of
CEQA provisions, the District has identified a limited number of District permitting activities
considered to be ministerial approvals. As set forth in §4.2.1 of the ERG, projects permitted
consistent with the District’s Guidelines for Expedited Application Review (GEAR) are standard
application reviews in which little or no discretion is used in issuing Authority to Construct
(ATC) documents.
For the proposed project, the District performed an Engineering Evaluation (this document)
and determined that the project qualifies for processing under the procedures set forth in the
District’s Permit Services Procedures Manual in the Guidelines for Expedited Application
Review (GEAR). Thus, as discussed above, this issuance of such ATC(s) is a ministerial
approval for the District and is not subject to CEQA provisions.
Page 23
Facility Name
Facility #, Project #
IX. Recommendations
Issue Authority to Construct C-xxxx-x-x subject to the permit conditions on the attached draft
Authority to Construct.
X. Billing Information
Permit Number
C-XXXX-X-X
Annual Permit Fees
Fee Schedule
Fee Description
3020-01-[ ]
[ ] Electric HP
Appendices
A:
B:
C:
D:
E:
BACT Guideline 2.1.3 & Top-Down BACT Analysis
Quarterly Net Emissions Change (QNEC)
HRA Summary
Draft Authority to Construct
Emissions Profile
Page 24
Annual Fee
$882.00
Facility Name
Facility #, Project #
APPENDIX A
BACT Guideline 2.1.3 & Top-Down BACT Analysis
Facility Name
Facility #, Project #
Facility Name
Facility #, Project #
Top-Down BACT Analysis
a. Step 1 - Identify All Possible VOC Control Technologies
The SJVUAPCD BACT Clearinghouse Guideline 2.1.3 identifies for this soil
remediation operation:
- 95% control efficiency for uncontrolled emissions above 2 lb/day
b. Step 2 - Eliminate Technologically Infeasible Options
There are no technologically infeasible options listed.
c. Step 3 - Rank Remaining Control Technologies by Control Effectiveness
- 95% control efficiency for uncontrolled emissions above 2 lb/day
d. Step 4 - Cost Effectiveness Analysis
The applicant is already proposing the most effective control technology
listed above. Therefore, per SJVUAPCD BACT policy, the cost
effectiveness analysis is not required.
e. Step 5 - Select BACT
The applicant is proposing BACT with the use of a carbon adsorption system
with a 95% or greater control efficiency.
Facility Name
Facility #, Project #
APPENDIX B
Quarterly Net Emissions Change (QNEC)
Facility Name
Facility #, Project #
Quarterly Net Emissions Change (QNEC)
The QNEC is entered into PAS database and subsequently reported to CARB. For
seasonal sources, or where the emissions differ quarter to quarter, then evaluate each
pollutant for each quarter separately. The QNEC is calculated for each pollutant, for
each unit, as the difference between the post-project quarterly potential to emit (PE2)
and the pre-project quarterly potential to emit (PE1).
The Quarterly Net Emissions Change is used to complete the emission profile screen
for the District’s PAS database. The QNEC shall be calculated as follows:
QNEC = PE2 - PE1, where:
QNEC = Quarterly Net Emissions Change for each emissions unit, lb/qtr.
PE2 = Post Project Potential to Emit for each emissions unit, lb/qtr.
PE1 = Pre-Project Potential to Emit for each emissions unit, lb/qtr.
Using the values in Sections VII.C.2 and VII.C.6 in the evaluation above, quarterly PE2
and quarterly PE1 can be calculated as follows:
EXAMPLE:
PE2quarterly = PE2annual  4 quarters/year
= 4,600 lb/year  4 qtr/year
= 1,150 lb VOC/qtr
PE1quarterly= PE1annual  4 quarters/year
= 4,600 lb/year  4 qtr/year
= 1,150 lb VOC/qtr
Quarterly NEC [QNEC]
PE2 (lb/qtr)
PE1 (lb/qtr)
QNEC (lb/qtr)
VOC
0
0
0
(Note: Include a table for each permit unit, if it makes sense to do so.)
Facility Name
Facility #, Project #
APPENDIX C
HRA Summary
Facility Name
Facility #, Project #
APPENDIX D
Draft Authority to Construct
Facility Name
Facility #, Project #
APPENDIX E
Emissions Profile
Facility Name
Facility #, Project #
Conditions
(Do Not Include With Application Review)
{1420} The soil remediation system shall be maintained in proper operating condition at
all times. [District Rule 2201] N
{15} No air contaminant shall be discharged into the atmosphere for a period or periods
aggregating more than three minutes in any one hour which is as dark as, or darker
than, Ringelmann 1 or 20% opacity. [District Rule 4101] N
{98} No air contaminant shall be released into the atmosphere which causes a public
nuisance. [District Rule 4102] N
If effluent VOC emissions are greater than 2.0 lb/day, the VOC control device shall be at
least 95% efficient in controlling the VOC from the soil remediation project. [District
Rule 2201] N
{2856} The total VOC emissions from the soil remediation system shall not exceed xxx
pounds in any one day. [District Rule 2201] N
{1422} Neither the soil ventilation rate nor the effluent gas flow rate shall exceed xxx
scfm. [District Rule 2201] N
The VOC concentration of the exhaust gas from the soil remediation system served by
the carbon adsorption shall not exceed xxx ppmv, as methane . [District Rule 2201]
{1412} A minimum of two carbon canisters which are connected in series shall be
utilized. [District Rule 2201] N
{1413} Sampling ports adequate for extraction of grab samples, measurement of gas
flow rate, and use of an FID, PID, or other District-approved VOC detection device shall
be provided for both the influent and the effluent gas streams. [District Rule 1081] N
{1414} Laboratory samples shall be taken at the initial inspection, under the supervision
of the APCD Inspector. Samples shall be taken from both the influent and the effluent
gas stream sampling ports. [District Rule 1081] N
{1416} Measurements to determine the influent and the effluent gas flow rates shall be
taken at the initial inspection. Flow rate calculations shall be submitted to the District
along with the laboratory sample analysis results. [District Rule 1081] N
{1417} Initial compliance with VOC emission rate and control efficiency requirements
shall be demonstrated by the results of the laboratory sample analysis. The results
shall be submitted to the District within 60 days of the test. [District Rule 1081] N
Sampling to demonstrate ongoing compliance with the VOC emission rate and control
efficiency requirements shall be performed at least once per week by sampling both the
Facility Name
Facility #, Project #
influent and the effluent gas streams with an FID, PID, or other District-approved VOC
detection device. [District Rule 1081] N
Control device may be taken off-line after uncontrolled VOC emissions from the soil
remediation operation does not exceed 2.0 lb/day, as demonstrated by five consecutive
weekly samples using a FID, PID, or other District-approved VOC detection device .
Once taken off-line, permittee shall conduct monthly sampling with a FID, PID, or other
District-approved VOC detection device to ensure uncontrolled VOC emissions do not
exceed 2.0 lb/day. If uncontrolled VOC emissions exceed 2.0 lb/day, the control device
shall be placed back on-line as soon as possible. [District Rule 2201] N
{1421} The carbon canisters removed from the system shall be sealed vapor tight.
[District Rule 2201] N
{1425} Records of the cumulative running time and the measured influent and effluent
VOC concentrations shall be maintained. [District Rule 2201] N
{2780} All records shall be retained for a minimum of five years, and shall be made
available for District inspection upon request. [District Rule 2201] N